1         Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

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We hope the following sections will answer any questions you have but if not, please do get in touch with us.

When you are using Sumo Technologies websites, Sumo Technologies Limited is the data controller.

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2          What legal basis do we rely on?

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

2.1        Consent

In specific situations, we can collect and process your data with your consent. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

2.2        Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.

2.3        Legal compliance

If the law requires us to, we may need to collect and process your data. 

2.4        Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

3         What sort of data do we collect?

We may collect the following information:

• Name

• Contact information including email address

• Demographic information such as postcode, preferences and interests

• Other information relevant to customer surveys and/or offers

4         What we do with the information we gather?

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• To process any orders that you make by using our website. If we don’t collect your personal data, we may not be able to process your order and comply with our legal obligations.

• To respond to your queries, refund requests and complaints. Handling the information, you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.

• To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.

• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.  If we discover any criminal activity or alleged criminal activity through our use of  fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts.  The aim is to protect the individuals we interact with from criminal activities.

• With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.

• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

• To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.

• To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

• To comply with our contractual or legal obligations to share data with law enforcement.  To send you surveys and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.

5         How we protect your data?

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. We secure access to our website using ‘https’ technology. Access to your personal data is password-protected.

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We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

6         How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

7         Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services.

• They may only use your data for the exact purposes we specify in our contract with them.

• We work closely with them to ensure that your privacy is respected and protected at all times.

• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

• Sharing your data with third parties for their own purposes:

• We will only do this in very specific circumstances, for example:

  • With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.

  • For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.

  • We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

For further information please contact our Data Protection Officer.

8         Where your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.

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An example of this is our Salesforce.com installation which is hosted in the USA.

9         Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.

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Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

10    What are your rights over your personal data?

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.

• The correction of your personal data when incorrect, out of date or incomplete: For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).

• That we stop using your personal data for direct marketing (either through specific channels, or all channels).

• That we stop any consent-based processing of your personal data after you withdraw that consent.

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You have the right to request a copy of any information about you that the company holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection Officer, Sumo Technologies Limited, 26A Manor Chambers, Marygate, York, YO30 7BH, or email admin@sumotech.com.  To ask for your information to be amended, please contact the fore mentioned contacts. 

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If we choose not to action your request we will explain to you the reasons for our refusal.

10.1    Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

10.2    Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

10.3    Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

10.4    Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

11    How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

·         Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails.

·         Write to our Data Protection Officer, Sumo Technologies Limited, 26A Manor Chambers, Marygate, York YO307BH

·         Email admin@sumotech.com

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

12    Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.

13    Use of cookies and other tracking technologies

Sumo Technologies, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, our Users and their Users-of-Users with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Visitor’s and Users’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.

Please note that Third Party Services placing cookies or utilizing other tracking technologies through our Services may have their own policies regarding how they collect and store information. Such practices are not covered by our Privacy Policy and we do not have any control over them.

13.1    Cookies

In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our services.

If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not provided by Sumo, and we, therefore, cannot ensure its accuracy, completeness or availability).

Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.

13.2    Clear Gifs

We and certain Third-Party Services may employ a software technology called “clear gifs” (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however are not stored on your device, but instead embedded within our Services.

13.3    Flash and HTML5

We and certain Third-Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, mainly for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies. Additional information about managing Flash cookies is available here.

(Please note that this website is not provided by Sumo, and we therefore cannot ensure its accuracy, completeness or availability).

13.4    Behavioural Targeting/Re-Targeting:

Certain Third-Party Services and ad networks may display advertising on our Website, on Sumo Apps and on Sumo mobile apps, or manage our advertising on other websites. Such parties may use certain tracking technologies to collect certain information about your activities on the Services and different third-party Services to provide you with targeted advertising based on your interests and preferences. You may opt-out of receiving targeted ads from certain advertisers and ad networks by clicking here (or if you are located in the European Union click here (provided by YourChoicesOnline.eu). Please note this does not opt you out of receiving all advertising and that your opt-out will only be in relation to the specific advertising. You will continue to receive advertising for which you have not opted out.

13.5    User Data Supplementation

We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyse our records, identify new customers, and provide products and Services that may be of interest to you. Where we obtain your Personal Information from these third parties, we ensure that such parties are contractually committed to inform you that your Personal Information will be disclosed to us and we take steps to ensure the accuracy of your Personal Information before using it. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

“Do Not Track” Signals: Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.

14    Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

15    Any questions

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact us.